Griffin Law Firm, PLLC

What would a Beneficiary Defective Inheritor's Trust actually move for your family? Our new modeler runs the installment sale on your own numbers, including the valuation discount, and shows how much lands outside your taxable estate at nine, twenty, and thirty years. Try it on our website.

The seed gift in a Beneficiary Defective Inheritor's Trust is $5,000, and not a dollar more. Exceed the five-or-five limit and the lapse of the beneficiary's withdrawal right becomes a transfer by the beneficiary — partially self-settling the trust and undoing the estate exclusion and the creditor protection.

New on the blog: the Beneficiary Defective Inheritor's Trust. A third party seeds it with $5,000. The beneficiary sells a discounted family partnership interest to it for an installment note, recognizes no gain, and the growth accrues outside the estate. We cover the mechanics, the economics, and the risks. Link in comments.

There is a trust structure in which the beneficiary is treated as the owner for income tax purposes and owns nothing for estate tax purposes. That is not a drafting accident or a loophole — it follows directly from how the statutes are built. This month we take apart the Beneficiary Defective Inheritor's Trust.

Is PPLI worth exploring for your situation? Our new tool compares a taxable portfolio against a PPLI-wrapped one over 10, 20, and 30 years using your own return and tax assumptions, and shows the point where the policy pulls ahead. Over decades, the after-tax difference can run into the millions. Try it on our website.

The rule that makes or breaks a PPLI policy is investor control. You may choose the investment manager and set the strategy, but you cannot direct the individual trades. Cross that line and the IRS treats you as the owner of the assets, unwinding the entire tax benefit retroactively — as one investor learned the hard way in Tax Court.

New on the blog: PPLI, explained. How a compliant insurance wrapper turns heavily taxed investment income into tax-free growth, tax-free access during life, and a tax-free death benefit — plus the IRS diversification and investor-control rules that make or break it, and why the buy-in keeps it in the ultra-wealthy lane. Link in comments.

What if you could hold hedge funds, private equity, or private credit — and never pay income tax on the gains? Private Placement Life Insurance is the structure ultra-high-net-worth families use to do exactly that. This month we pull back the curtain on how it works, and who it is actually for.

Not sure whether you need a full fund, a single-deal syndication, or a simple joint venture? Our new tool walks you through the key questions — how many investors, what type, how you'll raise, how much capital — then recommends a structure and estimates what it costs to launch. Try it on our website, and let's talk.

A small fund's annual overhead — administration, audit, tax, and compliance — often runs into six figures. At a typical 2% management fee, the fund doesn't break even until roughly $5 to $6 million in assets. Raise less than that, and a clean single-deal syndication is usually the better business decision.